Edwards Answer to Amicus Brief of CELC

8/14/2019 Edwards Answer to Amicus Brief of CELC

1/19

No. S147190

IN TIlE SUPREME COURTOF THE STATE OF CALIFORNIA

RAYMOND EDWARDS II,

Plaintiff and Appellant,

vs.

ARTHUR ANDERSEN, LLP,

Defendant and Respondent.

After a Decision by the Court of AppealSecond Appellate District, Division Three, Case No. B 178246

Lo s Angeles Superior Court Case No. BC 294853Andria K. Richey, Judge Presiding

ANSWER TO THE AMICUS BRIEF OFCALIFORNIA EMPLOYMENT LAW COUNCIL

AND ACTIVISION, INC.

LA W OFFICES OF RICHARD A. LOVERichard A. Love, SBN 61944

Beth A. Shenfeld, SBN 1162231160I Wilshire Boulevard, Suite 2000Los Angeles, California 90025-1756

(310) 477-2070 / Facsimile (310) 477-3922

GREINES, MARTIN, STEIN & RICHLAND LLPMarc J. Poster, SBN 48493Robin Meadow, SBN 51126

5700 Wilshire Boulevard, Suite 375Los Angeles, California 90036-3626

(310) 859-7811 / Facsimile (310) 276-5261

Attorneys for Plaintiff and AppellantRAYMOND EDWARDS II


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INTRODUCTION

LEGAL ARGUMENT

TABLE OF CONTENTS

Page

1

2

1. CELC MISREADS CALIFORNIA LAW; BUSINESSAN D PROFESSIONS CODE SECTION 16600 DOES NOTPERMIT SOME NONCOMPETITION AGREEMENTS; IT

VOIDS THEM ALL AS CONTRARY TO PUBLICPOLICY. 2

II . CELC'S PROPOSED REVISION OF CALIFORNIA LA WBY ADOPTION OF A CASE-BY-CASE ANALYSIS OFNONCOMPETITION AGREEMENTS WOULD DEFEATTH E BENEFICIAL PURPOSES OF SECTION 16600. 5

III. FORCING AN EMPLOYEE TO RELEASE "ANY ANDALL" CLAIMS IS A WRONGFUL AC T WHEN TH EEMPLOYEE MAY HAVE A CLAIM FO RINDEMNIFICATION UNDER LABOR CODESECTION 2802. 8

IV. THERE IS NO REASON TO LIMIT THIS COURT'SDECISION TO PROSPECTIVE APPLICATION ONLY. 9

CONCLUSION I 1

CERTIFICATE OF COMPLIANCE 12


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TABLE OF AUTHORITIES

Cases

Arthur Murray Dance Studios of Cleveland v. Witter(Ohio 1952) 105 N.E.2d 685

Boughton v. Socony Mobil Oil Co.(1964) 231 Cal.App.2d 188

Chamberlain v. Augustine(1916) 172 Cal. 285

Citizens for Covenant Compliance v. Anderson

(1995) 12 Cal.4th 345

Elden v. Sheldon(1988) 46 Cal .3d 267

Golden State Linen Service, Inc. v. Vidalin(1977) 69 Cal .App.3d 1

Gordon v. Landau(1958) 49 Cal .2d 690

Hill Medical Corp. v. Wycoff(2001) 86 Cal.AppAth 895

International Business Machines Corp. v. Bajorek(9th Cir. 1999) 191 F.3d 1033

King v. Gerold(1952) 109 Cal.App.2d 316

Loral Corp. v. Moyes(1985) 174 Cal.App.3d 268

Metro Traffic Control, Inc. v. Shadow Traffic Network(1994) 22 Cal.AppAth 853

11

Page

1

4

5 ,9

10

6

5

3

5

2

4

4

5


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TABLE OF AUTHORITIES (Continued)

Cases

Morris v. Harris(1954) 127 Cal.App.2d 476

Peterson v. Superior Court(1982) 31 Cal.3d 147

Scott v. Snelling and Snelling, Inc.(N.D.Cal. 1990) 732 F.Supp. 1034

Western Security Bank v. Superior Court

(1997) 15 Cal.4th 232

Whyte v. Schlage Lock Co.(2002) 101 Cal.App.4th 1443

Statutes

Business and Professions Code section 16600

Labor Code section 2802

Labor Code section 2804

Other Authorities

Page

5

10

5

9

6

2,4-5, 8-9

8-11

10

Arnow-Richman, Bargainingfor Loyalty in the Information Age:A Reconsideration o f the Role o f Substantive Fairness in EnforcingEmployee Noncompetes

(2001) 80 Or. L. Rev. 1163 7

Stone, Knowledge at Work: Disputes Over the Ownership o fHuman Capital in the Changing Workplace

(2002) 34 Conn. L. Rev. 721 7

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INTRODUCTION

The law of noncompetition agreements "is a sea - vast and

vacillating, overlapping and bewildering. One can fish out of it any kind of

strange support for anything, ifhe lives so long." (Arthur Murray Dance

Studios ofClevelandv. Witter (Ohio 1952) 105 N.E.2d 685, 687.)

The California Employment Law Council and Activision, Inc.

("CELC") have gone fishing. In their amicus brief, they have reeled in

some of that "strange support" for their position that, under California law,

if a noncornpetition agreement "is narrowly tailored to the surrounding

circumstances and leaves a substantial portion of the market available, it

falls outside [o f Business and Professions Code] Section 16600." (CELC

Brief, p. 2.)1

A thoughtful reading of the California cases, however, contradicts

CELC's position. Outside of express statutory exceptions, California law

has never upheld restraints - narrow or otherwise - on the right to practice

one's trade or profession. A bright-line rule is a good thing when it comes

to a right so fundamental as the right to earn a living. CELC's proposed

case-by-case, fuzzy-line rule would only encourage employers to push the

envelope of "narrowness," discourage unsophisticated employees from

exercising their rights, and invite unproductive litigation.

Similarly, there is no support for CELC's position that releases of

"any and all" claims must be interpreted to mean "some but not other"

claims.

CELC and Activision do not speak for all employers, of course.Some employers realize that noncompetition agreements are not only illegalbut contrary to their best interests in the long run. (See, e.g., the amicusbrief of St. Jude Medical, S.C., Inc., Pacesetter, Inc. and Advanced BionicsCorporation, filed May 23,2007, in support ofplaintiffs position.)

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In this answer, plaintiffRaymond Edwards II explains each of these

points.

LEGAL ARGUMENT

I. CELC MISREADS CALIFORNIA LAW; BUSINESS AND

PROFESSIONS CODE SECTION 16600 DOES NOT PERMIT

SOME NONCOMPETITION AGREEMENTS; IT VOIDS

THEM ALL AS CONTRARY TO PUBLIC POLICY.

CELC's amicus brief is premised on notions that section 16600

endorses noncompetition agreements that either "leave[] a substantial

portion o f the market available" to the employee (CELC Brief, p. 2) or

"tend more to promote than restrain trade" (CELC Brief, p. 10).

These premises are wrong, and the California cases relied on by

CELC don't hold otherwise. As plaintiffhas explained in his Answer Brief

on the Merits (at pp. 16-18,22-24,31) - and as the briefs of amici curiae

Law Professors and Writers of Learned Treatises (at pp. 6-12) and St. Jude

Medical, S.C., Inc., Pacesetter, Inc., and Advanced Bionics Corporation (at

pp. 9-22) have explained - the California cases relied on by CELC involve

issues beyond plain competition; they involve such distinct issues as

protection of trade secrets or prevention of unfair competition by means o f

unlawful solicitation of a former employer's other employees.

CELC essentially asks the Court to adopt the Ninth Circuit's version

of noncompetition law in place o f actual California law. With all due

respect to the Ninth Circuit, that court has in the past misread California

law. Indeed, a subsequent Ninth Circuit decision has admitted as much.

(International Business Machines Corp. v. Bajorek (9th CiT. 1999) 191 F.3d

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1033,1041 [noting that the narrow restraint exception has been rejected by

modern California cases, but "[w]e are not free to read California law

without deferring to our own precedent on how to construe it"].)

CELC's, and the Ninth's Circuit's, position depends on an

assortment of rulings cobbled together from a few California cases that

involve either no noncompetition agreement or a noncompetition agreement

that encompasses more than just a restraint on the right to practice one's

business, trade or profession. 2 We briefly reiterate what CELC

misunderstands about these inapposite cases:

Gordon v. Landau (1958) 49 Cal.2d 690, was a trade secrets

case. The Court upheld an employee's agreement not to use confidential

customer lists. (ld. at p. 694 ["a list of such customers is a valuable trade

secret and [] plaintiffs were damaged by defendant's unlawful use

thereof'].) CELC contends that the Court's trade secrets holding was not

the dispositive factor because the Court also stated that the contract did not

prevent the former employee from carrying on his business. (CELC Brief,

p. 6.) The case cannot fairly be read that way. The trade secrets violation

clearly was the factor that motivated the Court to reverse the judgment in

favor of the former employee. Indeed, ifCELC's reading of the case were

correct, the Court would not have mentioned the trade secrets violation at

all.

2 CELC's brief is also chock full of unsubstantiated factual assertions.I t informs us that "[n]ormally," despite having procured a general releasefrom departing employees, "employers fully comply with their obligation toindemnifY employees for expenses incurred in the course of theiremployment. . . . " (CELC Brief, p. 2.) That has not been plaintiffsexperience in this case. Nor has the good faith of employers beendemonstrated by the facts of actual cases referred to in the amicus briefs ofKastner Banchero LLP (at pp. 6-10) and St. Jude, etc., et al. (at pp. 2-3,fn. I).

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King v. Gerold (1952) 109 Ca1.App.2d 316, was an unfair

competition case. No employee was involved. The court upheld a

provision in a license to produce trailers designed by the licensor that, on

terminationof

the license, the licensee would not continue to producetrailers o f the licensor's design. The licensee could continue to

manufacture trailers, just not trailers that violated the plaintiffs design

rights.

Boughton v. Socony Mobil Oil Co. (1964) 231 Ca1.App.2d

188, was a real property case. Again, no employee was involved. The court

upheld a restriction on the use of real property contained in a contract for

the sale of the property.

Loral Corp. v. Moyes (1985) 174 Ca1.App.3d 268, involved a

former corporate executive's breach of a negotiated termination and stock

buy-out agreement that included his promise not to lure corporate

employees away from his former company to work for his new company.

(Id. at pp. 273-274.) The agreement did not limit the executive's right to

work for the new company or to compete for his old company's business.

The issue on appeal was whether the executive's agreement not to raid

employees from his former company was valid, and the court held it was

valid because employee raiding was equivalent to violation of a trade secret

or unfair competition. (Id. at p. 279 ["This does not appear to be any more

o f a significant restraint on his engaging in his profession, trade or business

than a restraint on solicitation of customers or on disclosure of confidential

information"].)I f there is dicta in Loral that would support CELC's plea for a non

statutory "narrow restraint" exception to section 16600, both prior and

subsequent California case law over the past century makes clear there is no

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such exception. (Chamberlain v, Augustine (1916) 172 Cal. 285, 289 ["The

statute makes no exception in favor of contracts only in partial restraint of

trade"]; Morris v, Harris (1954) 127 Cal.App.2d 476, 478 [same]; Golden

State Linen Service, Inc, v, Vidalin (1977) 69 Cal.App.3d 1, 12 [section16600 bars limited territorial restraints on employment]; Hill Medical Corp,

v. Wycoff(2001) 86 Cal.AppAth 895, 900-901 [limited territorial

restrictions on employment are void; "California codified its public policy

and rejected the common law 'rule of reasonableness' in 1872, upon the

enactment of the Civil Code"]; Metro Traffic Control, Inc, v, Shadow

Traffic Network (1994) 22 Cal.AppAth 853, 860 ["section 16600 prohibits

the enforcement of Metro's noncompete clause except as is necessary to

protect trade secrets"]; and see Scott v, Snelling and Snelling, Inc, (ND.Cal.

1990) 732 F.Supp. 1034, 1042 [no "rule of reason" exception for limited

territorial restrictions on competition; "California courts have been clear in

their expression that section 16600 represents a strong public policy of the

state which should not be diluted by judicial fiat"; the statute "should be

interpreted as broadly as its language reads"].)

II. CELC'S PROPOSED REVISION OF CALIFORNIA LAW BY

ADOPTION OF A CASE-BY-CASE ANALYSIS OF

NONCOMPETITION AGREEMENTS WOULD DEFEAT THE

BENEFICIAL PURPOSES OF SECTION 16600.

Ironically, CELC's amicus brief demonstrates the near-complete

uselessness o f a "narrow restraint" standard. CELC proposes a multi-part

test for the validity of each noncompetition agreement on a case-by-case

basis, founded on "the actual text o f the contract and the surrounding

circumstances" and measured by four additional factors, each of which is in

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turn broken into subparts, and which, just in summary, fill nearly an entire

page, single spaced. (CELC Brief, p. 12.)

CELC's proposed multi-part standards would be unworkable. They

are rife with undefined and undefinable weasel words such as "modest

limitations," "reasonably limited restrictions," and "overall positive or

negative impact." (Ibid.) Inventive counsel could extend or shrink these

vague concepts to fit almost any situation.

A multi-part, case-by-case test would offer fertile ground for other

mischiefas well. For example, while CELC pays lip service to California's

rejection o f the "inevitable disclosure" doctrine that employers have

unsuccessfully attempted to use to prevent employees with knowledge of

trade secrets from seeking any other employment in the same industry

(CELC Brief, p.16 [acknowledging that Whyte v. Schlage Lock Co. (2002)

101 Cal.AppAth 1443, 1462-1463, rejected the doctrine]), CELC's

proposed "confidential information/unlawful conduct" factor would

resurrect that doctrine by factoring in "How essential is the provision to

protecting against the employee's ability to place the information at risk?"

(CELC Brief, p. 12). This would extend beyond actually preventing misuse

of trade secrets and would prohibit the mere possibility of misuse of trade

secrets - a euphemism for the banned inevitable-disclosure doctrine. 3

Sometimes a bright line rule is essential. (Elden v. Sheldon (1988)

46 Cal.3d 267,277.) This is one of those times.

3 CELC also seeks to revive and extend the inevitable-disclosuredoctrine by allowing "the parties to negotiate their affairs from thebeginning with a complete understanding and agreement as to theirexpectations and limitations." (CELC Brief, p. 16, fn. 6.) The notion thatthe typical prospective employee can negotiate on a level playing field withhis or her prospective employer is highly illusory.

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On the public policy front, CELC professes concern about protecting

an employer's investment in human capital. (CELC Brief, pp. 13-16.)

CELC forgets that the employee pays for that capital by devoting himself or

herself to the employer's enterprise as the capital accumulates. 4 Moreover,

the human-capital argument loses all force when the employer also insists

that the employee serve at will and without job security. The employer

expects the employee's loyalty, but promises none in return. 5

In any event, the human-capital argument would enable virtually any

employer to justifY a noncompetition agreement on grounds that the

employee learned something during his or her employment, even if it were

only entry-level skills that anyone would learn holding almost any job. (Seethe amicus brief of California Employment Lawyers Association, at pp. 7-8,

enumerating some of the types of employment in which employers have

attempted to extract promises o f post-employment noncompetition

including such honorable but not skill-intensive occupations as janitors,

garbage collectors, and night watchmen.)

4 See Stone, Knowledge at Work: Disputes Over the Ownership o fHuman Capital in the Changing Workplace (2002) 34 Conn. L. Rev. 721,754 ("when human capital development is part o f what an employee ispromised in the employment deal, it must then be concluded that theresulting human capital so obtained belongs to the employee").

5 See Arnow-Richman, Bargainingfor Loyalty in the informationAge: A Reconsideration o f the Role o f Substantive Fairness in Enforcing

Employee Noncompetes (2001) 80 Or. L. Rev. 1163, 1209, 1218 ("Theproblem for employers, however, is how to encourage dedication andabove-average performance while simultaneously telling employees theyhave no guarantee of continued employment and may be terminated for anyreason" and "since noncompetes do not contractually define any otheraspect of the employment relationship, they create no legal obligation on thepart of the employer to fulfill any o f its own commitments . . .").

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CELC's only legitimate eoneems about potential misconduct by

former employees are properly addressed by California's trade secrets and

unfair competition laws, not section 16600. There is no need or

justification for the Court to rewrite section 16600 and add a complex andeasily manipulated "narrow restraint" exception.

III. FORCING AN EMPLOYEE TO RELEASE "ANY AND ALL"

CLAIMS IS A WRONGFUL A CT W HE N TH E EMPLOYEE

MA Y HAVE A C LA IM F OR INDEMNIFICATION UNDER

LABOR CODE SECTION 2802.

CELC fears that if a general release of "any and all claims" is found

to violate public policy in one respect, "Plaintiffs' counsel throughout the

State of California will contend that if a release is against public policy the

release is totally void." (CELC Brief, pp. 3-4.) But that is unfounded

speculation. Plaintiff does not take that position in this case. None of the

amicus briefs in his support have either. And, contrary to CELC's

assertion, the Court of Appeal did not either. What the Court of Appeal

condemned as violative of public policy was not a negotiated settlement of

an existing claim for employment benefits under section 2802, but rather

"forcing an employee to waive his or her statutory rights" under that

section. (Slip Opinion, p. 31 [emphasis added] citations omitted.)

As CELC concedes, in the typical case "the employee will not have

the faintest idea what claims cannot be released as matter oflaw." (CELC

Brief, p. 19.) The burden therefore should be on the employer to ensure

that releases do not purport to release rights that cannot lawfully be

released. If it is "impossible to list all claims which carmot be waived"

(CELC Brief, p. 19), then the employer should at least provide in the release

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that it is not intended to release claims that cannot lawfully be released.

That would at least water down the in terrorum effect o f a general release.

And if, as in this case, the employer is on notice that the employee may

have a claim for indemnification for employment related expenses pursuantto section 2802, the employer should expressly identify that claim as not

subject to the release. Forcing an employee to waive future rights under

section 2802 is one of the wrongful acts that plaintiff asserts as the basis of

his claim for interference with prospective economic advantage.

Finally, CELC suggests that "release agreements should be written

as simply as possible." (CELC Brief, p. 21.) But clarity, not mere

simplicity, must be the primary goal. I f simplicity results in confusion and

leads employees unnecessarily to refrain from exercising their statutory

rights, then simplicity should not be the paramount goal.

IV. THERE IS NO REASON TO LIMIT THIS COURT'S

DECISION TO PROSPECTIVE APPLICATION ONLY.

CELC asks that any rulings by this Court that there is no narrow

restraint exception to section 16600, or that a general release of future rights

under section 2802 violates public policy, should be prospective only.

(CELC Brief, pp. 17,23.)

There is no reason to limit the Court 's decision in this way. While

statutes that adopt new substantive rules are presumed to act prospectively

(Western Security Bankv.

Superior Court (1997) 15 Cal.4th 232, 242-243),section 16600 has been on the books in almost identical form since 1872.

This Court confirmed that the statute means what it says more than ninety

years ago, in 1916. (Chamberlain v. Augustine, supra, 172 Cal. at p. 289

["The statute makes no exception in favor of contracts only in partial

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restraint o f trade"].) Labor Code sections 2802 and 2804 have been on the

books since 1937. Employers have had seventy years to draft releases that

comply with those laws.

Case law, on the other hand, is presumed to act retrospectively.(Peterson v. Superior Court (1982) 31 Cal.3d 147, 151-152.) Plaintiff is

not seeking "dramatic changes" in the law, as CELC asserts. (CELC Brief,

p. 17.) And even if there were some uncertainty in California law before

now (there was none) "[r]eplacing chaos with certainty need not be reserved

for the future only." (Citizens for Covenant Compliance v. Anderson

(1995) 12 Cal.4th 345,367.)

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CONCLUSION

CELC's fishing expedition has netted nothing but arguments that

shouldbe

thrown back.CELC offers no explanation how any noncompetition agreement

would "tend more to promote than restrain trade." (CELC Brief, p. 23.)

The Legislature thought otherwise when it adopted section 16600 in 1872,

and it has continued to think so ever since. The statute should be given its

plain meaning rather than muddied with a judicially-created and

undefinable test of "narrowness."

Similarly, CELC has no explanation how a release of "any and all"

claims can reasonably be interpreted to mean "some but not all" claims.

Public policy prohibits an employer from forcing an employee to release

claims that cannot lawfully be released.

Dated: June lL, 2007

LAW OFFICES OF RICHARD A. LOVERichard A. LoveBeth A. Shenfeld

GREINES, MARTIN, STEIN & RICHLAND LLPMarc J. PosterRobin Meadow

By ~ ~ - ~ r - ,f : ' - ' - s ~ : ' - ' - q . - - Attorneys for Plaintiff and AppellantRAYMOND EDWARDS II

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CERTIFICATE OF COMPLIANCE

Pursuant to California Rules of Court, rule 8.204 (c)(l), the attached

Answert o

Amicus Brief Of California Employment Law Council AndActivision, Inc. was produced using 13-point Times New Roman type style

and contains 2,773 words not including the tables of contents and

authorities, caption page, signature blocks, or this Certification page, as

counted by the word processing program used to generate it.

Dated: June 1I, 2007

LAW OFFICES OF RICHARD A. LOVE

GREINES, MARTIN, STEIN & RICHLAND LLP

By & . ~ # - r , - ' - ~ - " ' ~

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PROOF OF SERVICE

STATE OF CALIFORNIA ))

COUNTY OF LOS ANGELES )

I am employed in the County of Los Angeles, State of California. I am over the age of 18and not a party to the within action; my business address is 5700 Wilshire Boulevard, Suite 375,Los Angeles, California 90036-3626.

On June 12,2007, I served the foregoing document described as Answer To TheAmicus Brief Of California Employment Law Council And Activision, Inc. on the interestedparties in this action by placing a true copy thereof enclosed in sealed envelopes as stated below.

xx BYMAIL

I caused such envelope to be deposited in the mail at Los Angeles, California. Theenvelope was mailed with postage thereon fully prepaid as follows:

SEE ATTACHED SERVICE LIST

I am "readily familiar" with firm's practice of collection and processing correspondencefor mailing. I t is deposited with U.S. postal service on that same day in the ordinary course ofbusiness. I am aware that on motion o f party served, service is presumed invalid i f postalcancellation date or postage meter date is more than 1 day after date o f deposit for mailing inaffidavit.

Executed on June 12,2007, at Los Angeles, California.

X (State) I declare under penalty of perjury under the laws o f the State o f California that theforegoing is true and correct.


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SERVICE LIST

Wayne S. Flick, Esq.Yury Kapgan, Esq.Latham & Watkins LLP633 West Fifth Street, Suite 4000

Los Angeles, CA 90071-2007

Kristine 1. Wilkes, Esq.Colleen C. Smith, Esq.Shireen M. Becker, Esq.Latham & Watkins LLP600 West Broadway, Suite 1800San Diego, CA 92101-3375

Sharon A. McFadden, Esq. (courtesy copy)Arthur Andersen LLP33 West Monroe Street, Floor 18Chicago,IL 60603-5385Attorneys for Defendant and Respondent ARTHUR ANDERSEN LLP

Eric C. Kastner, Esq.Scott R. Raber, Esq.Newton Kastner & Remmel20 California Street, 7th FloorSan Francisco, CA 94111Attorneys for Amicus Curiae KASTNER BANCHERO LLP

James Pooley, Esq.Morrison & Foerster LLP755 Page Mill RoadPalo Alto, CA 94304-1018

Mark A. Lemley, Esq.Stanford School o f Law559 Nathan Abbott WayStanford, CA 94305-8610Attorneys for Amicus Curiae LA W PROFESSORS AND WRITERS OFLEARNED TREATIES

Paul Grossman, Esq.Jennifer S. Baldocchi, Esq.Paul, Hastings, Janofsky & Walker LLP515 South Flower Street, 25th FloorLos Angeles, CA 90071Attorneys for Amici Curiae CALIFORNIA EMPLOYMENT LA W COUNCILand ACTIVISION, INC.


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SERVICE LIST (Continued)

James A. Gale, Esq.Todd M. Malynn, Esq.Michael J. Weber, Esq.Feldman Gale, P.A.880 West First Street, Suite 315Los Angeles, CA 90012Attorneys for Amici Curiae ST. JUDE MEDICAL, S.c., INC., PACESETTER, INC.and ADVANCED BIONICS CORPORATION

Jeffrey K. Winikow, Esq.Law Offices of Jeffrey K. Winikow180 I Century Park East, Suite 1520Los Angeles, CA 90067Attorneys for Amieus Curiae CALIFORNIA EMPLOYMENT LAWYERSASSOCIATION

Scott H. Dunham, Esq.O'Melveny & Myers LLP400 South Hope StreetLos Angeles, CA 90071-2899Attorneys for Amicus Curiae EMPLOYERS GROUP

Clerk for theHonorable Andria K. RicheyLos Angeles Superior Court111 North Hill StreetLos Angeles, CA 90012

Office of the ClerkCourt of AppealSecond Appellate District, Division Three300 South Spring StreetSecond Floor, North TowerLos Angeles, CA 90013-1233

Documents

Edwards Answer to Amicus Brief of CELC